Frequently Asked Questions - Area-based Analysis
EIMS development has been focused on selection of wildlife species with previous interactions with oil and gas activities and all WHA and UWR in northeast B.C.
The Area-based Analysis (ABA) approach has been developed by the BC Oil and Gas Commission (the Commission) as a framework for managing the impacts of oil and gas development. It is a different and more effective way of characterizing landscape of unconventional gas basins to inform decisions on oil and gas applications.
The Commission uses ABA to address the long-term effects of oil and gas activity in its decision making. Various decisions involving roads, water, seismic activity, well and facility locations, and pipeline corridors cause cumulative effects to both environmental and social values. Considering effects on only a project- or sector-specific basis can allow unintended impacts to accumulate over time.
In contrast, the Commission is addressing cumulative effects of oil and gas activity through the Areabased Analysis approach to permitting and authorizing. This approach allows the Commission to manage industry activity comprehensively to protect ecological, social and cultural heritage values. The actions that will be assessed are the combined footprint impact of industrial development on the selected values. For the Commission, that means that decisions about oil and gas activities will be made with all industrial development in mind.
Area-based Analysis considers all oil and gas activities and the surface and subsurface environmental impacts, both current and potential, at the full basin scale to achieve better environmental outcomes and more effective and efficient regulation. That means that broad impacts can be considered when looking at specific applications or activities, rather than just the localized effects of one permit. It evaluates the overall landscape – including features such as existingroads, wildlife management zones and other industrial users.
It’s an approach that manages environmental values based on direction set by government. ABA gives the Commission a better picture of the cumulative and larger impact of oil and gas activities for an entire region within the overall context of all activity. This information is used when the Commission makes decisions on applications.
Area-based Analysis follows the adaptive management process – the Commission will monitor to measure impacts, and adjust the overall framework as required.
|Values included||Target date|
|Hydro-riparian ecosystems, Old Forest||Fall 2014|
|High priority wildlife||2015|
First Nation cultural, heritage and traditional use
The ABA proof of concept was focused on landscape and ecological values within the Liard Unconventional Gas Basin. This ecological and landscape focus will be retained as ABA is deployed across the entire land base of northeast British Columbia (see Figure 2).
Compiling all known data and information into area-specific analyses gives industry, First Nations, government and other stakeholders the same information used by the Commission.
All documentation, data and analytical procedures used in ABA will be shared with all First Nations communities.
Area-based analysis integrates strategic direction from statutes, regulations and existing land-use plans with identified environmental and cultural values into a coherent and clarified framework.
This framework will:
- Provide a consistent rationale and process for identifying environmental and cultural values.
- Clarify objectives as set out in government policy and statutes.
- Provide an analysis of all existing development and the opportunity for future oil and gas activity.
- Provide a simplified and transparent framework to assess and manage oil and gas development impacts on identified values
The Area-Based Analysis (ABA) approach uses components of common cumulative effects assessment processes, but is geared to be operational. It will help inform decision makers about the impacts of oil and gas applications in the broader context of all development.
Area-Based Analysis is also used to evaluate trends in resource development and the effectiveness of policy regimes. Area-Based Analysis reports will be updated periodically to reflect new information, including updates to relevant government policy and legislation and new development activities.
The principle behind ABA is that as the impact to a value increases due to industrial build out by all activity, not just oil and gas, the management response escalates.
An assessment framework is developed for each value (see Figure 1) and the information generated during the assessment is provided to the Statutory Decision Maker for use in their decision.
The goal of the Area-based Analysis framework is to maintain conditions in the bottom bar where permitting is subject to routine reviews and operating procedures.
In the event the enhanced management trigger has been reached and the current condition of the value is determined to be in the middle (yellow) bar, the permitting process is subject to additional review and additional operating procedures will considered.
The objective is to return the conditions below the enhanced management trigger. FIGURE 1
In the event regulatory/policy trigger has been reached and the current condition of the value is determined to be in the top (orange) bar, the permitting process is subject to additional senior/regional staff review and additional operating procedures will considered.
The objective will be to restore conditions below the regulatory/policy trigger and ideally below the enhanced management trigger. This may include suspending permitting, confirming policy direction and implementing innovative approaches to mitigate the impact.
The framework is designed to be modular, and work is under way on five values:
- hydro-riparian ecosystems (riparian habitat, water quantity)
- old forest
- high-priority wildlife habitat
- resource features
- cultural heritage resources.
Three additional values are planned:
- ground water
- water quality
- air quality.
If additional values are identified through the First Nations engagement process, they will be considered for inclusion within the framework.
The measurement of disturbance will be assessed against triggers/thresholds that have been established by expert opinion. These thresholds will trigger actions that will reduce the impact of further development, by introducing avoidance and mitigation strategies.
The actions that will be assessed are the combined footprint impact of all industrial development on the selected values. This includes all surface land use disturbance associated with oil and gas activity, geophysical activity, cutblocks and non-oil activity (such as mining, recreation, hydro, wind power, transmission lines). For the Commission, that means that decisions about oil and gas activities will be made with all industrial development in mind.
Area-based Analysis has been expanded to cover the full extent of the Western Canadian Sedimentary Basin in northeast British Columbia (NEBC). This includes the key development basins: The Horn River, the Cordova Embayment, the Montney and the Liard Basin.
The initial values being assessed focus on the biophysical components of the ecosystem. This includes 650,000 hectares of hydro-riparian reserves and 3.5 million hectares of Old Forest.
The ABA process monitors all industrial disturbance in a comprehensive incursion database.
Embodied in the existing environmental legislation and policy regime that governs resource management within British Columbia is the concept of “coarse-filter” and “fine-filter” management.
Coarse-filter management refers to the conservation of landscapes through networks of protected areas and management zones that allow natural processes to persist. Conserving the ecological communities of a given region through coarse filter management will also conserve those species that co-occur on the landscape, share common ecological processes and/or threats and are expected to behave similarly to development pressures and management actions.
Some species, ecosystems and features need to be conserved through individual, often localized efforts because they fall through the mesh of the coarse filter. This process is termed fine-filter management, and refers to conservation through localized protection measures such as individual species protection plans or protection of critical habitats or features (dens or rookeries) that are requisite for key life functions.
This framework was used to define the suite of starting values, as well as to help define the nesting of related values. The starting values are:
- hydro-riparian ecosystems (riparian habitat, water quantity)
- old forest
- high priority wildlife habitat
- resource features
- cultural heritage resources
ABA fits into the existing legal framework within which the BC Oil and Gas Commission operates. This legal framework is an environmental protection regime that is embodied in the collection of acts, regulations, standards, practice requirements and management plans that govern the mandate of the BC Oil and Gas Commission.
The legal framework was developed over many years. It is based on a wealth of information and knowledge about the activities on the ground and/or the environmental components. Overall the legal framework is intended to balance scientific knowledge with management risk, while protecting the environment and enabling development.
ABA gives the Commission greater certainty that decisions about oil and gas activity are made within the legal framework and that the effects of oil and gas activity can be managed and mitigated effectively and to lasting effect.
Some of the specific concerns ABA will help address include:
- Clarification of current legal/policy objectives in the Oil and Gas Activities Act (OGAA) and the Environmental Protection and Management Regulation (EPMR), which are both administered by the Commission.
- In conjunction with the cumulative effects program of the Ministry of Forest Lands and Natural Resource Operations (FLNRO), the ABA will:
- Address the situation that multiple government agencies permit and authorize different industries and activities that impact the same values on the same land base
- develop common objectives and shared information to minimize or eliminate the accumulation of unintended impacts
- ensure the assessment(s) informs decision-making in a coordinated and consistent manner across the natural resource sector in order to reduce unintended impacts on values
- address the cumulative environmental effects of all natural resource activities and events on a select set of resource values (rather than just oil and gas, for instance).
- The ABA will assist in addressing concerns by
- identifying and making coordinated decisions about significant resource development in northeast British Columbia
- managing the impacts of development on key ecosystem attributes (habitat, water, air, species) to stay within acceptable levels
- managing the impacts of development on the resource values that support the practice of treaty rights.
Area-based Analysis (ABA) follows the outline identified in the 1999 document “Cumulative Effects Assessment Practitioners Guide” prepared for the Canadian Environmental Assessment Agency.
Scoping consists of five basic steps:
- identify the issues of concern
- select the appropriate values
- identify the spatial and temporal boundaries
- identify the actions that impact the values
- identify potential impacts from the actions and possible effects.
One of the best methods to reduce resource development and environmental/cultural conflict is to share the information available with all interested parties. Identifying the values important to each First Nation ensures that these values are recognized and considered early in the application process. Sensitive data and information can be protected, and transparent and regular reporting on the information important to First Nations can occur.
Area-based Analysis was introduced to First Nations in conjunction with FLNRO’s (Forests, Lands and Natural Resource Operations) presentation on cumulative effects during two workshops in January 2013 in Fort St John. First Nations unanimously requested, and the FLNRO and the Commission committed to working directly with each community to define specific interests and next steps.
Since then the FLNRO and the Commission have participated in further engagement with all First Nations in the northeast region by providing background materials, holding face-to-face meetings with interested First Nations within their communities and distributing both the draft assessment report completed for the South Peace area and the methods paper for the ABA approach.
Many First Nations have chosen to work directly with the FLNRO and the Commission specifically on incorporating First Nations values of interest, providing additional data and reviewing the preliminary assessment methods and results.
Most Consultation Process Agreements (CPA) are being re-negotiated and alternative approaches such as ABA being brought forward in discussion with application consultation processes.
Area-based Analysis (ABA) is intended to provide a structured assessment of values for consideration in decision making. ABA could include an assessment of those resource values that are important to or contribute to the practice of treaty rights. Preliminary discussions have commenced with some First Nations communities on how to develop a structured assessment of specific environmental, cultural and heritage values within ABA that are tied to the practice of treaty rights.
They are not exclusive but they do meet different needs on different scales.
The Environmental Assessment Office ensures proposed major projects meet provincial environmental, economic and social goals, and the interests and concerns of B.C.’s families, businesses, communities and First Nations are considered in each assessment. The Environmental Assessment Office evaluates proposed projects that are reviewable under the Environmental Assessment Act for potential adverse environmental, economic, social, heritage and health effects and verifies and enforces compliance with the conditions of environmental assessment certificates. The projects subject to review are generally those with a higher potential for adverse environmental, economic, social, heritage or health effects.
The ABA framework was developed to be an ongoing component of permitting decisions within the Commission; it had to be implementable so that the concerns about cumulative effects could be more readily addressed. Adjustments in current permitting/authorization processes, additional data and new GIS (Geographic Information System) tools were required, and the stakeholder consultation critical to implementation success was needed.
ABA is designed to be adaptable so that when changes to legislation/policy are introduced, or existing values/objectives are modified, the Commission can easily introduce the changes to a system that is operating, and understood, accepted and supported by all involved. New additional environmental / cultural considerations can be added to the analysis when they are identified and provided sufficient spatial data exists and can be incorporated.
The Oil and Gas Commission’s Area-based Analysis (ABA) approach supports B.C.’s legal framework that manages values.
The Commission and the Ministry of Forest, Lands and Natural Resource Operations (FLNRO) have been collaborating on the development of ABA and the Northeast Cumulative Effects Assessment and Management (CEAM) demonstration project.
Both are a values-based approach to assessing and managing the cumulative effects of activity. Both ABA and CEAM supplement a comprehensive suite of natural resource policy and legislative tools that are in place to address cumulative effects in B.C.
These policy and legislative tools in turn provide a legal framework to proactively and comprehensively manage the cumulative impacts of development by multiple resources within the same region.
This encompassing system, or legal framework, includes:
- Resource-focused legislation/policy providing both strategic and operational guidance for resource extraction, management and environmental protection.
- Specific legislation to assess the cumulative effects of proposed major projects that have potential impacts over and above the resource-focused legislation.
- A comprehensive land use and resource management planning system implemented over the majority of B.C.
- Province-wide stewardship staff focused on monitoring the condition of the environment.
- Formal engagement processes, formal consultation procedures and government-to-government agreements between First Nations Communities, the Government and the many ministries and agencies involved in the management of natural resources.
ABA and CEAM assist this system to achieve a more consistent and coordinated approach to cumulative effects assessment and management across the natural resource sector. They address the issue of multiple agencies permitting activities that impact the same values on the same land base.
The Commission and the FLNRO are developing one database to ensure consistency between both initiatives. ABA will be used as part of the Commission’s permitting and authorization process to assess the impact of proposed oil and gas activities considering the cumulative effects of all development activity.
In conjunction with FLNRO, key data input and assumptions will be validated through 2015 with a field assessment in the summer of 2015. Two specific areas that will be assessed include:
- The accuracy of predicting a field-based riparian class assessment from an air photo interpretation of riparian features.
- The reliability of the assumption that there has been no ecological succession, reclamation or reforestation on any disturbance, and that the impact that occurred with the initial disturbance has not changed, regardless of when it occurred.
- The first priority for these reviews is the Lower Pine River water management basin.
In addition, the OGC will:
- Continue to work with First Nations through community-focused engagement sessions to review ABA results and explore avenues for incorporating cultural heritage resources.
- Unveil a public web site with all relevant documentation and data: January 2015
- High priority wildlife value go live: 2015
- Cultural heritage resources values go live: 2015
- Other values (air quality, water quality, ground water): when ready
The principle behind ABA is that as the impact to a value increases due to industrial build out, management response escalates. The Commission has developed ABA-specific permit conditions to help address the incremental impacts of any activity. These conditions will be considered by Commission staff for all permits and authorizations for those values when the current condition is above Enhanced Management Trigger or above the Regulatory Policy Trigger. This will commence when ABA goes live.
As of January 2015, 27 of the 69 water management basins are above the Enhanced Management Trigger. All Natural Disturbance Units have sufficient Old Forest to meet the specified targets. These results are subject to change. Current ABA Status is available in the ABA shapefiles and Quarterly Reports.
Area-based Analysis (ABA) is a valuable tool for decision makers and resource managers to better manage the environment and minimize further impacts. ABA quickly draws attention to areas where significant cumulative effects exist and allows for a greater understanding of disturbance.
ABA will assess the combined footprint of all industrial development on the selected values. For the Commission, that means that decisions about oil and gas activities will be made with all industrial development in mind.
The best available information is used in ABA however because the data and the analytical techniques are necessarily simplifications of the real world, the technical information and analysis does not necessarily provide a complete picture of all aspects of the value, nor all answers or solutions.
Ongoing studies and monitoring will improve knowledge and increase certainty with time. All data have limitations, and usually require assumptions to use, which in turn creates strengths and weaknesses that need to be considered within a decision. Detailed documentation regarding input data, limitations, sourcing, and methodology is contained in the report “Project Analysis and Implementation: Area-based Analysis” available on the ABA web page, including the key assumptions for all input data.
The technical information and analysis does not provide the complete answer or solution to ABAfocused permitting or authorization decisions. To ensure a fair and equitable assessment, in addition to the information describing data / analysis uncertainty, an assessment of other risks will be provided in conjunction with the ABA assessment.
A comprehensive section on ABA is on the Commission’s website. The Commission has endeavored to provide all the documentation required to incorporate ABA in applications. We expect that the materials on this website will answer any questions or concerns. If you are unable to find the answer in the material available:
- For comments/questions on the overall ABA program design and direction, next steps, permit conditions, planning considerations, and overall management please send an email to Sean.firstname.lastname@example.org
- For comments or questions about the data used, key assumptions, assessment methodology, discrepancies between the mapped data and field conditions, data errors, please send an email to email@example.com
To make the most effective applications and avoid delays or returns, Industry should include ABA as an integral part of planning an oil or gas activity. ABA is about planning oil and gas activities in a way that minimizes the footprint of activities, and reduces restoration / reclamation timeframes on environmental values.
- Review ABA Website
- Review the FAQs available on the ABA Website.
- Download the ABA Riparian Habitat dataset for use in development planning
- Download the ABA Old Forest dataset for use in development planning
- During the development planning process consider:
- What is the current condition and status of Riparian Habitat in the development area?
- What is the current condition and status of Old Forest in the development area?
- How can I plan the activity to avoid Old Forest & Riparian Habitat?
- What can I do to minimize disturbance?
- Use existing disturbance, unless doing so would result in a greater disturbance, greater safety risk, significant operational difficulty and/or negative environmental impacts
- Consider low impact seismic techniques such as wireless technology and meandering lines
- Use common access and shared corridors
- Consider using winter access in old forest and riparian reserve zones
- Leverage use of directional drilling and multiwell pads to minimize disturbance
- Place auxiliary disturbance outside sensitive areas
- Minimize new land disturbance
- Implement strategies that will expedite reclamation
- During the development planning process review existing disturbance on the landscape and use this where possible to minimize impact on the ABA values
Where ABA indicates that the condition of the riparian and old forest value do not exceed any triggers, existing regulatory requirements and associated guidance need be considered in relation to these values.
Where a trigger has been exceeded, the considerations identified above will be expected of industry as they prepare applications for submission, and additional permit and authorization conditions may be included to reduce the proposed impact.
As well, the Commission is actively:
- Reviewing key data and assumptions in conjunction with the Ministry of Forests and Natural Resource Operations (FLNRO), Specifically the two organizations are working together to:
- Determine, for each type of disturbance, the relevance and impact of ecological succession, re-vegetation, reclamation, restoration and forest management on the riparian and old forest values
- Establish a collaborative field program to understand the accuracy of the inventory and GIS-based assumptions relative to field conditions
- Reviewing the existing plans (LRMP’s & SRMP’s) for additional guidance supporting the refinement of triggers
- Reviewing the policy process that helped create the triggers
If the results are material, ABA will be re-run, if not the results will stand as-is.
- Planning and Operational Measures (POMs) clarifies the Commissions expectations, and allows for a consistent review process for all applicants, POMS also reduce the requirements for a mitigation strategies, except in areas of escalated environmental concern. The EPMG provides guidance on interpretation of the EPMR. With the implementation of POMs the Commission has gone one step further by clarifying planning and operational expectations for oil and gas activities in areas of environmental value.
- The POMs are provided to both applicants and Decision Makers. This provides for consistency in the review process and common understanding of objectives and expected actions for oil and gas activities. In areas under order with ABA Status normal, applications meeting the POMs negates the previous requirements for a Mitigation Strategy.
Currently to indicate compliance with Planning and Operational Measures (POM) an applicant needs to complete the following information in the stewardship tab:
Does the application adhere to the Environmental Protection and Management Guideline? YES/NO (defaults to NO)
If Yes, nothing further is required
If No, the mandatory mitigation strategy upload will prompt (this is where a rationale or mitigation strategy, if required, should be uploaded).
A second question will prompt you to confirm if an exemption requested from Part 3 of the Environmental Protection and Management Regulation.
This question defaults to NO and does not apply to Planning and Operational Measures.
In the near future AMS will be updating the wording in this section to specify adherence to Planning and Operational Measures.
A rationale is a brief statement of reason, or a logical basis, to justify a course of action proposed by a proponent. A rationale is required when an application for an oil and gas activity is not consistent with the POMs provided by the Commission for a specific environmental value. Rationales must:
Be prepared by a Qualified Professional
Include an explanation of why the oil and gas activity cannot be planned to be consistent with the planning and operational measures provided by the Commission.
Provide a detailed description of the alternate measures planned for the activity and describe how desired outcomes specified in the planning and operational measures will be achieved.
Mitigation Strategy Requirements
A Mitigation Strategy is a formal document capturing a proponent’s commitment to mitigation and monitoring, including mitigation goals, mitigation actions and the specific measures that will be carried out. A mitigation strategy is required when a proposed activity is within 100 metres of water works and/or water supply well, in cases where the Commission has not defined POMs for the environmental value overlapped (impacted), or where the ABA Status is either enhanced management or regulatory policy. A Mitigation Strategy may also be required in specific circumstances at the discretion of a statutory decision maker. Mitigation Strategies must be prepared in accordance with Appendix B of the Environmental Protection and Management Guideline.
Appendix B of the EMPG provides minimal guidelines for Mitigation Strategy documents.
In addition ABA Mitigation Plans should include:
- An explanation of any efforts made to coordinate access and development with other industrial users with operations in the area.
- A detailed rationale is required when the applicant does not demonstrate avoidance, use of existing disturbance or shared access.
- A detailed account of any criteria that were considered to minimize the disturbance footprint in well site design, such as alignment to fit local topography, limited use of cut and fill, minimizing pad size, avoidance of sensitive areas and actions to reduce the number of trees harvested.
- A detailed explanation and/or a map of any site specific measures employed to minimize disturbance to soil and vegetation including plans that minimize impact to the duff layer (such as limited stumping/grubbing, frozen ground access, use of rig matting, use of low ground pressure equipment and soil management for restoration).
- A detailed explanation and/or a map of any site-specific measures employed to limit disturbance by the roadway, such narrowing the cleared width of the right of way and limiting ground disturbance for the running surface and ditch lines.
- A detailed explanation and/or a map of any site-specific measures employed to limit disturbance by pipeline construction, such as use of trenchless technology and reduction of workspace requirements on either side of the crossing.
- A detailed explanation and/or a map of any site-specific geophysical survey design elements used to minimize disturbance, such as avoidance, dead-ending at riparian zones, cutting restrictions limited to brush and understory, meandering avoidance, doglegs and mulch management.
- A detailed explanation and/or a map of any site-specific remediation and/or prescriptions for restoration and recovery, including actions related to access control, spreading coarse woody debris, mounding, planting and/or seeding.
- A detailed explanation of minimal disturbance strategies for activity in Riparian Reserve Zones. This should include an erosion risk assessment, sediment control, timing considerations, stability analysis, minimal tree felling (away from watercourse), re-establishing vegetation, contingency measures, and a post construction recovery and monitoring plan.
- Rationale detailing operational need or relevant constraints to justify any exceedance of the documented expectations for well pad area.
- A detailed account of any considerations that support the objectives of the area within which the activity is proposed
- Any other information that may support the proposed development being permitted within the Old Forest or Riparian Reserve Zone as proposed.